UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIA--------------------------------------------------------------------XRACHEL BERNSTEIN; STUART HERSH; RONMORITZ; JOEL BAILEY; JERE FINER; DANIELLAFINER; MOSHE FULD; HAIM BARAD; LOUISMURRAY LIPSKY; IRA HARTMAN; KERENEIZENBERG; CHANIE GELLER; GREG GELLER;RACHEL STERN; MARTHA LEV-ZION;NORMAN MESKIN; CHERYL MESKIN;WILLIAM WERBLOWSKY; MARK REBACZ; AVIPENKOWER; MONTY PERNKOWER; SUSANIRELAND, BRIAN NORIN AND NATHANLAMM,Plaintiffs,-against-HILLARY R. CLINTON, in her official capacity asSecretary of the United States Department of State;THOMAS R. NIDES, in his official capacity asDeputy Secretary of State for Management andResources; JOHN DOE, Director, Office of U.S.Foreign Assistance Resources, in his officialcapacity; UNITED STATES DEPARTMENT OFSTATE; RAJIV SHAH, in his official capacity asAdministrator of the United States Agency forInternational Development; and UNITED STATESAGENCY FOR INTERNATIONALDEVELOPMENT,Defendants.--------------------------------------------------------------------X12 Civ. _______ (___)

COMPLAINT

Jury Trial Demanded

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Plaintiffs, complaining of the defendants, by their attorney, NORMANSTEINER, ATTORNEY AT LAW, alleges for their complaint as follows:

NATURE OF ACTION

1.

Plaintiffs are all American citizens who reside in Israel. All livefearful of terrorist attacks against them. They bring this action to ensure their securityand to cause United States governmental funding in violation of legal requirements andCongressional regulations to the Palestinian Authority and the United Nations Reliefand Works Agency for Palestine Refugees in the Near East (“UNRWA”) to cease.2.

Plaintiffs are all innocent civilians who live in close proximity tothe Palestinian Authority and are the Americans most likely to be harmed byPalestinian terrorism. Several are victims of previous Palestinian terrorist attacks.3.

Defendants have authorized, sanctioned, encouraged, and/orfacilitated funding to the Palestinian Authority without imposing the controls andoversight mandated by federal statute. In addition, Defendants have ignored reportingrequirements and allowed the Palestinian Authority to evade transparency safeguardsmandated by American law. In so doing, they have allowed federal dollars into thehands of Hamas and the Popular Front for the Liberation of Palestine (both recognizedforeign terrorist organizations), the Palestinian Liberation Organization (a terroristorganization), employees of the Palestinian Authority who are barred access to federalfunds pursuant to federal statute, and other supporters of terrorism against civilianswho live in Israel.

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4.

Illicit federal funding endangers the lives of the Plaintiffs and theirloved ones.5.

Plaintiffs bring this action to stop that funding, demand that illegaldisbursements be divested from the Palestinian Authority, that any future funding be incompliance with U.S. law and regulations and to secure their safety.

JURISDICTION AND VENUE

6.

This Court has jurisdiction over the claims in this action pursuantto 28 U.S.C. §§ 1331 (action arising under the laws of the United States), 1346(a)(2)(United States as defendant), and 1361 (mandamus).7.

Venue lies in this district pursuant to 28 U.S.C. § 1391(b) and (e).8.

Upon information and belief, all Defendants reside in the Districtof Columbia.9.

A substantial part of the events giving rise to this action look placewithin the District of Columbia.

PARTIESA. Plaintiffs

10.

Plaintiff Rachel Bernstein is an American citizen who resides inIsrael. She was injured in a terrorist attack in 1976 in Jerusalem.11.

Plaintiff Stuart Hersh is an American who citizen who resides inIsrael. He was injured in a 1997 suicide bombing in Jerusalem.12.